Sophia Li, Luke Meyer, Savannah Myers & Lucas Quinn, Thirty-Ninth Annual Survey of White Collar Crime: Tax Violations, 61 Am. Crim. L. Rev. 1113 (2024): 

This Article outlines the elements, defenses, and sentencing consequences of select criminal tax violations of Title 26 of the United States Code, the Internal Revenue Code ("I.R.C."), which are prosecuted under an array of criminal tax statutes. Section II of this article examines the policies and procedures of Internal Revenue Service ("IRS") criminal investigations. In doing so, it addresses the basic elements of, defenses to, and sanctions for five principal tax crimes: (i) tax evasion under I.R.C. § 7201; (ii) willful failure to collect tax under § 7202; (iii) willful failure to file taxes under § 7203; (iv) tax perjury and aiding and assisting tax fraud under § 7206; and (v) interference with the administration of internal revenue laws under § 7212(a). 

Sections III and IV examine criminal statutes that may implicate tax crimes but that are not within the I.R.C. Section III details criminal investigations of conspiracy to violate the tax laws under the "defraud clause" of the general federal conspiracy statute, 18 U.S.C. § 371. Section IV examines various criminal statutes within Titles 18 and 31 of the United States Code that relate to tax crimes.

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